ETHICS AND PLANNED
GIVING
The concept of ethics and ethical behavior is one
that most people would agree is a "good" concept, but not all people have the
same definition for what it means. Each person has his/her own set of standards
for conduct he considers to be ethical. Sometimes those standards differ
somewhat when we look at professional conduct as opposed to personal conduct.
Sometimes we can rationalize conduct in our professional life that we would
never condone in our personal life, or vice versa. Whether we approach this
concept from a philosophical, religious, or behavioral standpoint, most people
have internalized a personal concept of ethical behavior that guides them
through their lives. In affect, each of us has a set of rules we impose upon
ourselves as a guide to living.
Many professional organizations attempt
to control and standardize the conduct of the members of that profession by
adopting a code of conduct. This gives the members of that profession a guide by
which they can regulate their interactions with their clients and other members
of their profession. As a gift planner and a member of my professional
organization, I subscribe to the "Model Standards of Practice for the Charitable
Gift Planner" issued by the National Committee on Planned Giving. Each member of
NCPG must subscribe to these "Model Standards" to gain membership, and gift
planners are very careful not to push the boundaries of those standards.
Coming from a background in trust banking, it has always seemed to me
that the "Model Standards" of NCPG are very similar to rules governing fiduciary
relationships in a trust department. A fiduciary relationship demands a much
higher level of concern for people than ordinary relationships. In fact, the
word "fiduciary" means "trust."
As gift planners, we have a very close
relationship with our donors. We often know more about the finances, estates,
and future plans of our donors than do their own families. I subscribe to Robert
F. Sharpe, Jr.'s contention that those donors who provide for a planned gift has
elevated your charity (and you as the charity's representative) to the status of
family. We must treat this special relationship with the utmost respect.
Although we work for the charity and, of course, want to do what is necessary to
further its mission, we must not forget that we should never try to further the
charity's mission at the expense of the donor.
Who has never been
tempted to rush a donor into a gift arrangement in order to make the goals for
the year? And who has not thought about encouraging a donor to set up a
charitable gift annuity knowing that a trust arrangement or a simple bequest
would really be a better alternative for the donor? Gift planners face these
issues every day. We can argue forever about whether a specific behavior is
ethical or unethical, but splitting hairs is not the point. How can you be sure
what you are suggesting to the donor is "right?" The easiest test I know is to
simply ask yourself, "If this was my grandmother, would this be the advice I
would give her?"
In closing, I would like to share with you the ten NCPG
"Model Standards of Practice for the Charitable Gift Planner" mentioned above so
you will know the high standards by which we practice our
profession.
MODEL STANDARDS OF PRACTICE FOR THE
CHARITABLE GIFT PLANNER
I. Primacy of
Philanthropic Motivation
The principal basis for making a
charitable gift should be a desire on the part of the donor to support the work
of charitable institutions.
II. Explanation of Tax
Implications
Congress has provided tax incentives for charitable
giving, and the emphasis in this statement on philanthropic motivation in no way
minimizes the necessity and appropriateness of a full and accurate explanation
by the Gift Planner of those incentives and their implications.
III. Full Disclosure
It is essential to the gift
planning process that the role and relationships of all parties involved,
including how and by whom each is compensated, be fully disclosed to the donor.
A Gift Planner shall not act or purport to act as a representative of any
charity without the express knowledge and approval of the charity, and shall
not, while employed by the charity, act or purport to act as a representative of
the donor, without the express consent of both the charity and the donor.
IV. Compensation
Compensation paid to Gift Planners
shall be reasonable and proportionate to the services provided. Payment of
finders fees, commissions or other fees by a donee organization to an
independent Gift Planner as a condition for the delivery of a gift are never
appropriate. Such payments lead to abusive practices and may violate certain
state and federal regulations. Likewise, commission-based compensation for Gift
Planners who are employed by a charitable institution is never appropriate.
V. Competence and Professionalism
The Gift
Planner should strive to achieve and maintain a high degree of competence in his
or her chosen area, and shall advise donors only in areas in which he or she is
professionally qualified. It is a hallmark of professionalism for Gift Planners
that they realize when they have reached the limits of their knowledge and
expertise, and as a result, should include other professionals in the process.
Such relationships should be characterized by courtesy, tact and mutual respect.
VI. Consultation with Independent Advisors
A Gift
Planner acting on behalf of a charity shall in all cases strongly encourage the
donor to discuss the proposed gift with competent independent legal and tax
advisers of the donor's choice.
VII. Consultation with Charities
Although Gift Planners frequently and properly counsel donors
concerning specific charitable gifts without the prior knowledge or approval of
the donee organization, the Gift Planners, in order to insure that the gift will
accomplish the donor's objectives, should encourage the donor, early in the gift
planning process, to discuss the proposed gift with the charity to whom the gift
is to be made. In cases where the donor desires anonymity, the Gift Planners
shall endeavor, on behalf of the undisclosed donor, to obtain the charity's
input in the gift planning process.
VIII. Description and
Representation of Gift
The Gift Planner shall make every effort to
assure that the donor receives a full description and an accurate representation
of all aspects of any proposed charitable gift plan. The consequences for the
charity, the donor and, where applicable, the donor's family, should be
apparent, and the assumptions underlying any financial illustrations should be
realistic.
IX. Full Compliance
A Gift Planner shall
fully comply with and shall encourage other parties in the gift planning process
to fully comply with both the letter and spirit of all applicable federal and
state laws and regulations.
X. Public Trust
Gift
Planners shall, in all dealings with donors, institutions and other
professionals, act with fairness, honesty, integrity and openness. Except for
compensation received for services, the terms of which have been disclosed to
the donor, they shall have no vested interest that could result in personal
gain.